20190214Reply Comments.pdf

Y ROCKY MOUNTAIN
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RECEIVED
I'dl9 FEB lb Att l0:52
1407 W. North Temple, Suite 330
Salt Lake city, Utah 841l6
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February 14,2019
VIA OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472West Washington
Boise, ID 83702-5983
Attn: Diane Hanian
Commission Secretary
RE: Case No. PAC-E-18-12
In the Matter of the Application of Rocky Mountain Power For Authority to Decrease
Schedule l9l - Customer Efficiency Services Rate
Reply Comments
Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Reply
Comments in the above referenced matter.
Informal questions related to this matter may be directed to Ted Weston at [phone] or me
at [phone].
Sincerely,
Michael S. Snow
Manager, DSM Regulatory Affairs
Enclosures
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Daniel E. Solander, (lSB# 8931)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone: [phone]
Email: [e-mail]
Attorneyfor Rocly Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )oF ROCKY MOUNTATN POWER FOR )
AUTHORITY TO DECREASE SCHEDULE )191 CUSTOMER EFFICIENCY )
SERVICES RATE )
CASE NO. PAC-E.I8.I2
REPLY COMMENTS
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"), in
accordance with RP 052 and RP 201, et. seq., and hereby respectfully submits reply comments
to the Idaho Public Utilities Commission (the "Commission") in the above referenced matter.
BACKGROUND
l. On November 9,2018, the Company filed an Application with the Commission
requesting authorization to decrease Electric Service Schedule l9l - Customer Efficiency
Services Rate Adjustment ("Schedule l9l") from 2.75 percent to 2.25 percent. On
November 29,2018, the Commission noticedlthe Application and on January 17,2019,the
Commission issued a Notice of Modified Procedure2 for the above referenced matter, allowing
parties to file comments by February 7,2019, with the Company's reply comments due by
February 14,2019. Commission Staff ("Staff'), the Idaho Conservation League ("ICL"), and
the Community Action Partnership Association of Idaho ("CAPA[") filed comments
February 7,2019. Staff recommended that the Commission approve the Company's
I Order No, 34198.
2 Order No. 34230.
REPLY COMMENTS OF
ROCKY MOLINTAIN POWER
Page I
Application to decrease Schedule l9l rate to2.25 percent, effective March l,2019.lCL and
CAPAI recommended that the Commission maintain the current Schedule 191 rates until after
the conclusion of the 2019 Integrated Resource Plan ("lRP") process to ensure adequate
funding remains in the account to acquire energy savings targets. Rocky Mountain Power
provides these reply comments in response to comments filed by ICL and CAPAI.
REPLY COMMENTS
2. The Company's goals are aligned with the Commission's expressed desire that
electric utilities acquire cost-effective demand-side management ("DSM") energy efficiencies.
The request to reduce the Schedule l9l rate is consistent with that goal. The Company's reply
comments address three key issues raised by ICL and CAPAI:
o There is no reason to delay a decision until after the IRP is acknowledged;
o The rider rate does not influence the amount of DSM programs pursued; and
o The Company does not support ICL's recommendation to increase energy
education funding.
3. The Company disagrees with the recommendation from ICL and CAPAI to
defer any changes to Schedule l9l until the results of the IRP provide an updated basis to
establish a multi-year plan for programs and expenses. While the IRP helps inform and set
targets for energy efficiency achievements, it does not drive the results. The Company strives
to acquire cost-effective energy efficiencies as demonstrated in its DSM prudency filing.3 The
2015 IRP selected 33,370 MWh of energy efficiencies in Idaho for calendar years 2016 through
2017; the Company acquired 39,066 MWh of energy efficiency savings in ldaho, exceeding
the IRP selections for the same period. The IRP does not "shed valuable light on the rate of
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
Page2
3 PAC-E-18-07,page7.
collections over expenditures"4 as ICL claims, it is instead used as a tool by the Company to
select the most cost-efficient energy portfolio for its customers.
4. To encourage utilities to pursue cost-effective energy efficiency programs, the
Commission authorized the use of DSM balancing accounts to provided better certainty of cost
recovery of prudent DSM expenditures. Schedule 191 is a recovery mechanism associated with
this balancing account so the Company can be reimbursed for prudently incurred DSM
expenditures. It does not impact the level of DSM the Company will pursue.
5. Historically, the rate for Schedule l9l has been adjusted as needed to align
revenue collections with DSM expenditures. Attachment B to the Company's application was
provided to demonstrate that if the rate for Schedule l9l was reduced to 2.25 percent, as
recommended by the Company and Commission Staff, and DSM expenditures increased
between $200,000 to $300,000 per year from the 2018 expenditure level it would still take
three years, through the end of202l for the balancing account to be slightly under funded.
6. Based on historical and projected spend, estimated revenues, and the current
over-collected balance, the Company is forecasting that the Schedule l9l rate adjustment to
2.25 percent aligns with current projected expenditures, and will result in a balanced account
by December 31, 202l.Delaying an adjustmentto Schedule l9l until the conclusion of the
2019 IRP process would likely result in another year of collecting revenue at current rates,
which would further increase the over-collected balance. As noted, the Schedule l9l rate does
not influence the amount of DSM pursued. Allowing the balancing account to become
excessively over-collected is not in the public interest and does not follow the spirit of the
balancing account's purpose.
4 CAPAI comments page 2 third paragraph.
REPLY COMMENTS OF
ROCKY MOUNTATN POWER
Page 3
7. The Company will continue to pursue all cost-effective DSM to acquire energy
savings targets, regardless of the balancing account status, and continue to request adjustments
to Schedule l9l as needed to keep the account balanced.
8. The Company does not agree with or support ICL's recommendation to
increase energy education funding above the current $25,000 annual amount. Since the
implementation of education funding, the local agencies have struggled to use the current level
of funding, and this level can be adjusted in a future filing if the current annual amount is being
used on a consistent basis.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
approve the Company's Application to decrease Electric Service Schedule l9l - Energy
Efficiency Services rate to 2.25 percent, effective March l, 2019, consistent with Staff s
recommendation.
DATED this l4th Day of February,2019.
Respectfully submitted,
By
Daniel E. Solander
Attorney for Rocky Mountain Power
1,fih
REPLY COMMENTS OF
ROCKY MOLINTAIN POWER
Page 4
CERTIFICATE OF SERVICE
I hereby certiff that on this 14th of February,20lg,I caused to be served, via e-mail a true
and correct copy of Rocky Mountain Power's Reply Comments in Case No. PAC-E-18-12 to the
following:
Service List
Dated this 14th day of February,2019
Vet
Katie Savarin
Coordinator, Regulatory Operations
Commission Staff
Edward Jewell
Deputy Attomey General
Idaho Public Utilities Commission
472 W. Washington
PO Box 83720
Boise, lD 83720-0074
edward j ewell@puc. idaho. eov
PacifiCorp dba Rocky Mountain Power
Ted Weston
Michael S. Snow
PacifiCorp dba Rocky Mountain Power
1407 West North Temple
Suite 330
Salt Lake City, UT 84116
ted.weston@pacifi com. com
m ichael. snow@pacifi corp. com
Daniel E. Solander
PacifiCorp dba Rocky Mountain Power
1407 West North Temple
Suite 320
Salt Lake City, UT 841l6
danel. solander@pacifi com. com
Data Request Response Center
PacifiCorp
825 NE Multnomah,Suite 2000
Portland, OR97232
datareq uest@oaci fi corp.com
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